SEC v. Marcus

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 14, 2026
Docket17-2534
StatusUnpublished

This text of SEC v. Marcus (SEC v. Marcus) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SEC v. Marcus, (2d Cir. 2026).

Opinion

17-2534 SEC v. Marcus et al.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 14th day of January, two thousand twenty-six.

Present: DEBRA ANN LIVINGSTON, Chief Judge, DENNIS JACOBS, BARRINGTON D. PARKER, Circuit Judges. _____________________________________

UNITED STATES SECURITIES AND EXCHANGE COMMISSION,

Plaintiff-Appellee,

v. 17-2534 (Lead); 17-2537 (Con); 17-2681 (Con); 24-2751 (Con) PAUL MARCUS, THE DEANE J. MARCUS TRUST, THE STEVEN E. MARCUS TRUST, THE CHERYL MARCUS- PODHAIZER TRUST, THE EVE S. MARCUS CHILDREN’S TRUST,

LISA MEYER, DEBRA MAYER, ALFRED C. HEITKOENIG, ELNA CHARLOTTE HEITKOENIG, MAAKIE HEITKOENIG,

Interested Parties-Appellants,

1 AMERINDO INVESTMENT ADVISORS INC., ALBERTO WILLIAM VILAR, GARY ALAN TANAKA, AMERINDO ADVISORS UK LIMITED, AMERINDO MANAGEMENT INC., AMERINDO TECHNOLOGY GROWTH FUND, INC., AMERINDO TECHNOLOGY GROWTH FUND II, INC., TECHNO RAQUIA, S.A., AMERINDO INVESTMENT ADVISORS, INC. (PANAMA),

Defendants- Appellants. _____________________________________

For Plaintiff-Appellee: EMILY TRUE PARISE, Senior Appellate Counsel (Jeffrey B. Finnel, Acting General Counsel, Tracey A. Hardin, Solicitor, Stephen G. Yoder, on the brief), U.S. Securities and Exchange Commission, Washington D.C.

For Claimant-Appellant: JAMES A. MITCHELL (Bradley R. Gershel, on the brief), Ballard Spahr LLP, New York, New York. .

Appeal from an order of the United States District Court for the Southern District of New

York (Sullivan, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the order of the district court is AFFIRMED.

Claimants-Appellants Paul Marcus, The Deane J. Marcus Trust, The Steven E. Marcus

Trust, The Cheryl Marcus-Podhaizer Trust, and The Eve S. Marcus Children’s Trust (collectively,

the “Marcus Claimants”) appeal from the September 17, 2024 order of the United States District

Court for the Southern District of New York (Sullivan, J.), directing the remaining receivership

assets be distributed solely to the Securities and Exchange Commission (“SEC”) in partial

satisfaction of its outstanding penalty judgment. 1

1 Because Claimants-Appellants challenge only the 2024 Order in their briefs, they have waived any arguments regarding the interim distribution orders from which the 2017 Appeals were taken. See JP Morgan Chase Bank v. Altos Hornos de Mexico, S.A. de C.V., 412 F.3d 418, 428 (2d Cir. 2005) (“[A]rguments not made in an appellant’s opening brief are waived even if the appellant pursued those arguments in the district court or raised them in a reply brief.”). To the extent that the Mayer Claimants and Alfred Heitkoenig join in the Marcus Claimants’ arguments,

2 On appeal, the Marcus Claimants argue that the district court abused its discretion by (1)

improperly constraining its equitable authority in fashioning a remedy, (2) declining to

differentiate between Amerindo Technology Growth Fund (“ATGF”) investors and Guaranteed

Fixed Rate Deposit Account (“GFRDA”) investors, and (3) rejecting ATGF investors’ asserted

constructive trust rights in the surplus funds. We assume the parties’ familiarity with the

underlying facts, the procedural history of the case, and the issues on appeal, which we discuss

here only as necessary to explain our decision to AFFIRM.

* * *

“Once the district court has found federal securities law violations, it has broad equitable

power to fashion appropriate remedies . . . .” SEC v. Frohling, 851 F.3d 132, 138 (2d Cir.

2016) (internal quotation marks omitted). “We review the District Court’s decision relating to the

choice of distribution plan for the receivership estate for abuse of discretion.” SEC v. Credit

Bancorp, Ltd., 290 F.3d 80, 87 (2d Cir. 2002).

First, the Marcus Claimants argue that the district court erroneously concluded that it

lacked authority to distribute leftover profits to investors and thereby improperly constrained its

equitable powers. We disagree; the district court did not disclaim authority. Assuming arguendo

that the court possessed the authority to allocate surplus profits to investors at this stage, its refusal

to do so was, in any event, soundly grounded in its exercise of equitable discretion. The district

court crafted a three-part remedy that “returned investors’ principal investments, disgorged ill-

gotten gains, and imposed a civil penalty for the wrongdoing.” Sec. & Exch. Comm’n v. Amerindo

Inv. Advisors Inc., No. 05-CV-5231 (RJS), 2024 WL 4212459, at *5 (S.D.N.Y. Sept. 17, 2024).

those arguments fail for the reasons explained in this order. Any other arguments raised are waived because they were not presented in a timely opening brief. See id.

3 Through four interim distributions, the defrauded investors recouped “the entirety of the investors’

principal in the amount of $54,404,467.83, plus an inflation adjustment of $13,849,639.27.” Id.

at *1. Given that these distributions offset defendants’ disgorgement judgments, see id. at *1, “all

that remain[ed] [was] to discharge the SEC’s penalty judgment.” Id. at *5. Exercising its equitable

discretion, the district court concluded that there was no justification “to dole out extra payouts to

investors—who ha[d] already been repaid in full on their principal investments—while the SEC’s

penalty judgment [sat] unpaid.” Id. at *4. We discern no abuse of discretion in the district court’s

decision to direct the funds to the SEC.

Second, the Marcus Claimants argue that the district court abused its discretion by treating

ATGF and GFRDA investors as similarly situated. They contend that the district court overlooked

the fact that ATGF investors bargained for and accepted greater market risk than GFRDA investors

in anticipation of potentially higher returns.

However, the false representations used to induce investment—and investors’ subjective

expectations derived from these misrepresentations—are not dispositive. “[A] trustee or receiver

devising a distribution plan is not required to apportion assets in conformity with

misrepresentations and arbitrary allocations that were made by the defrauder, ‘otherwise, the whim

of the defrauder would . . . control[] the process that is supposed to unwind the fraud.’” Commodity

Futures Trading Comm’n v. Walsh, 712 F.3d 735, 749 (2d Cir. 2013) (quoting In re Bernard L.

Madoff Investment Securities LLC, 654 F.3d 229, 241 (2d Cir.2011)). Here, as the district court

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
SEC v. Marcus, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sec-v-marcus-ca2-2026.